APS Publishes Updated Reg E Compliance Playbook Following CFPB Guidance

Regulatory

Advantage Payment Services has published an updated Reg E Compliance Playbook in response to the Consumer Financial Protection Bureau’s revised supervisory guidance on error resolution procedures, issued in late 2024. The guidance clarified expectations around provisional credit timelines, required documentation at the point of dispute initiation, and acceptable methods for notifying cardholders of investigation outcomes. The APS playbook translates these expectations into operational checklists and platform configuration recommendations specific to Dispute Advantage users.

Key updates in the playbook include revised intake field requirements that align with the CFPB’s documentation standards, updated workflow templates for the ten-business-day and 45-calendar-day provisional credit scenarios, and a new audit checklist designed for institutions subject to upcoming exam cycles. APS compliance specialists worked with legal counsel to cross-reference the guidance against current Dispute Advantage default configurations and have identified two optional workflow adjustments recommended for institutions in higher-scrutiny examination environments.

The playbook is available in the APS Client Resource Center and will be discussed in depth during APS’s upcoming compliance webinar series, scheduled for February and March 2025. Clients who wish to schedule a one-on-one compliance configuration review with an APS specialist may contact their account manager directly.